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Industrial Industrial Painting & Painting & Coating Coating
Industrial Industrial Painting & Painting & Coating Coating
What Is SBEAP?
The Small Business Environmental Assistance Program, SBEAP, was initiated as a result of the Clean Air Act Amendments of 1990. SBEAP helps small businesses comply with environmental regulations by providing technical assistance, introducing businesses to pollution prevention practices, and offering compliance assistance to help with environmental permitting and reporting requirements. In Kansas, the Pollution Prevention Institute at Kansas State University is the technical assistance provider for SBEAP. All SBEAP services are completely confidential, non-regulatory, and free. Because services are free, SBEAP provides guidance in compliance and technical matters to businesses that otherwise would not have access to such help because of financial constraints. Its staff can introduce you to such practices as changes in product design, substitution of materials, process optimization, waste minimization, and recyclingall of which can help diminish the burden of compliance and protect the environment. SBEAP operates independently of the Kansas Department of Health and Environment, KDHE, but coordinates with the agency to ensure that SBEAPs interpretation of Kansas regulations is consistent with KDHE's intent. To obtain technical assistance or request an on-site assessment, call 800-578-8898. SBEAP also operates a Web page at www.sbeap.org. It contains SBEAP publications, including our quarterly newsletter, Kansas AIRlines. It also has industry-specific information and a calendar of events.
Table of Contents
Introduction .....................................................................................................................3 Substrate Surface Preparation..............................................................................4 Coating Application ..............................................................................................6 Drying and Curing ................................................................................................8 Coating Application Types and Technologies ..................................................................9 Low-Volume High-Pressure Spray (LVHP) Systems ...........................................10 High-Volume Low-Pressure (HVLP) Systems ....................................................11 Powder Coatings .................................................................................................13 Electrostatic Paint Systems ................................................................................14 Airless and Air-Assisted Airless Systems............................................................15 Other Technologies.............................................................................................16 Comparison of Coatings .................................................................................................19 High-Solids Coatings...........................................................................................20 Water-Based Coatings .........................................................................................21 Powder Coating...................................................................................................22 Ultraviolet (UV) Radiation-Cured Coatings........................................................23 Pollution Prevention for the Coating Industry...............................................................24 Hierarchy of Pollution Prevention Strategies .....................................................26 Priority 1: Source Reduction..............................................................................27 Priority 2: Recycle and Reuse ............................................................................33 Coating Operator Techniques ........................................................................................35 Regulatory Issues............................................................................................................37 Waste Disposal Regulations ................................................................................38 Air Regulations ...................................................................................................49 Wastewater Regulations......................................................................................57 Water Regulations...............................................................................................59 Community Right-to-Know Regulations.............................................................60 Health and Safety ...............................................................................................63 Where to Find Help ........................................................................................................64
Introduction
Paint usage has environmental impacts at all stages of its life cycle, including manufacturing, application, and eventual disposal. The purpose of this manual is to provide general background information on environmental compliance requirements for painting application operations, with specific emphasis on minimizing wastes through pollution prevention. The manual reviews various coating applications, coating types, pollution prevention opportunities, and environmental regulations. If you have questions or would like further information on materials presented here, you can contact an SBEAP specialist by calling 800-578-8898, or view any of our publications by visiting our Web site at www.sbeap.org. Why paint? Paints and other surface coatings provide protection to a product, as well as being decorative and eye-catching. Generally, paint type and means of application are dependent upon what function the coating must perform. General steps for painting and coating applications typically include the following:
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Preparatory, application, and drying processes chosen depend on many factors, including your clients demands and anticipated rate at which you have to get products finished and delivered.
Surface Preparation
Surface preparation of the material (substrate) to be painted is very important. As high as 80% or more of all coating adhesion failures can be directly attributed to improper surface preparation.1 A substrate must be clean before a coating is applied. Improper preparation can lead to a lower quality or defective product, or one that is not visually appealing. The most common forms of surface debris are oils or greases that originated from mechanical processing, or are deliberately applied for purposes of corrosion prevention during temporary storage or shipping. Other surface contaminants commonly include oxidation, rust, corrosion, heat scale, tarnish, and in some cases, old paint. Dirt, grease, or other similar materials will block the bonding surface and create an imperfection on the finished part. Proper preparation improves the bond between the coating material and the surface, and ensures the coating is applied and adheres in a uniform manner. Examine your operations and see if there is a way to minimize the amount of cleaning required by keeping your substrate from getting dirty during storage or processing.
Mechanical Cleaning
The first step in your preparation process should be mechanical cleaning. Wiping loose dust and dirt off your parts with a rag is an easy example. More vigorous action may be needed to remove rust or other contaminants strongly attached to the part. For wood surfaces, sanding followed by wiping with a lint-free cloth is effective. For metal substrates, metal scale and rust can be removed by brushing the part with a wire brush, a sand or grit blaster, or plastic wool pads.
North Carolina Division of Pollution Prevention and Environmental Assistance, April 1998, Pollution Prevention in Metal Painting and Coating Operations
Chemical-assisted Cleaning
Another option for preparing your parts for painting includes chemicalassisted cleaning. Traditionally, solvents have been used to remove oilytype contaminants through wiping, spraying, dipping, or vapor degreasing. But there are problems associated with solvent cleaning. Spraying can be wasteful, dip tanks can lead to large quantities of hazardous waste being generated, and vapor degreasers are regulated under environmental laws and pose a potential health hazard. Also, solvent-contaminated rags may need to be disposed of as hazardous waste. With such issues in mind, some have switched from solvent to aqueous cleaning, which is generally more environmentally friendly. Acidic solutions effectively remove rust, scale, and oxides from metal surfaces, but can cause hydrogen embrittlement as hydrogen gas formed penetrates the metal and reduces its strength. Mild alkaline solutions are used to clean and remove rust and scale from metal substrates because no hydrogen embrittlement results. Elevated temperature solutions are more effective for removing greases and oils, but the energy consumption needs to be considered.
Conversion Coatings
For those working with metal substrates, a conversion coating may be applied to metal prior to painting to improve adhesion, corrosion resistance, and thermal compatibility. Conversion coatings chemically react with the metal surface to build a more complex physical surface that improves the bonding of the coating. Iron and zinc phosphate coatings are usually used for steel. Iron, zinc, and chromium phosphate are all used when it comes to coatings for aluminum, with the choice of solution largely depending on the volume of aluminum being processed.
Coating Applications
Which paint or coating application process you choose will depend on your particular operations. What is the material you are coating? What are the chemical and physical characteristics the coating must have? What is the shape and size of the productdoes it have a unique shape that might make uniform application more difficult? How many products must you paint each shift? Several factors affect how good the paint coverage is on the piece, as well as the transfer efficiency of the application. Transfer efficiency is the relationship between the amount of paint you apply and the amount of paint actually adhering to the part being coated. The higher the transfer efficiency of your process, the more paint you are getting on your part and the less overspray you have. Your equipment and booth setup, the type of paint youre applying, the particular product youre coating, and your painting operators skill all factor into how efficiently youre using your paint. Coatings consist of resins, pigments, solvents, and additives. Particular types of coatings youre applying will have varying amounts of each of these constituents. Resins or binders hold all paint constituents together and enable them to cure into a thin plastic film. Resins are made up of polymers, which are chosen based on physical and chemical properties desired in the finished product. Acrylics produce a shiny, hard finish with good chemical and weather resistance. Alkyds are relatively low in cost and because of their versatility are considered a general purpose paint. Epoxies provide excellent water resistance and superior chemical resistance, but do lose their gloss from ultraviolet light. Urethanes combine high gloss and flexibility with chemical stain resistance, and demonstrate excellent water resistance.
Pigments are tiny particles insoluble in paint incorporated to improve the physical appearance of the coating. Additives are also used to impart specific physical or chemical properties to the coating. Some pigments or additives may contain metals which may classify any resulting solid wastes as hazardous. Paint performance may be improved by adding curing agents, defoamers, gloss modifiers, or other agents. Solvents are used to carry the coating solids to the part being painted. They are also added to paint to aid in its application by reducing viscosity so the coating may be easily applied. Solvents are a major source of environmental concern in coating applications because as curing occurs, hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) are released.
Many of these same chemicals may cause any solid wastes generated as part of your painting operations to become hazardous wastes. Additionally, any discarded products may fall under the Resource Conservation and Recovery Act (RCRA), or hazardous waste regulations. The next chapter goes into detail about different coating application types and technologies currently being used.
LVHP
Low-volume high-pressure spray (LVHP) is considered the conventional method of applying coatings. It depends on air-atomizing the paint at pressures of 4070 pounds per square inch (psi). Air is supplied from an air compressor or turbine. While these spray systems create high quality finishes at high production rates, they do have several disadvantages, including extensive overspray, increased booth cleanup costs, and increased filter use and related costs. Additionally, if a higher coating thickness is necessary, more operator passes may be necessary to get the desired mil thickness, and hence application time is increased.
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HVLP
The principle of high-volume lowpressure (HVLP) has been applied to conventional spray guns to apply paint with a high volume of dispersing air at low pressures. HVLP guns have nozzles with larger diameter openings for atomizing air, can be bleeder or non-bleeder types, and require air volumes of 1030 cubic feet per minute. Air and fluid delivery to the spray gun affect the efficiency, ease of use, cost, and versatility of HVLP sprayers. In a siphon-fed HVLP system, air pressure to the sprayer is used to pull paint from the cup located below the gun, producing a fully atomized pattern for even surface coverage. Gravity-fed HVLP systems are well adapted for higher viscosity paints, such as clears, water-based paints, high-solids paints, and epoxy primers, given the paint cup location. The cup, located at the top of the gun, allows paint to completely drain, minimizing paint waste. HVLP guns allow operators to finish intricate parts with comparable quality to conventional sprayers. This makes them a good choice for small shops that finish smaller, more intricate parts which demand a higher level of gun control. Other advantages of the HVLP system include the following:
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transfer efficiencies, from 50 to 90 percent reported, depending on the air-delivery system used reduced amount of overspray, and hence material use reduced VOC and HAP emissions reduced paint booth filter use and cleanup costs reduced worker exposure due to high-pressure blowback from the spray good coverage of intricate parts finish quality comparable to conventional air sprayers
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comparable transfer efficiencies to air-assisted airless sprayers at low-fluid delivery rates, with low to medium viscosity fluids more efficient air atomization air-spray coating adaptable to any size coating operation and application rate equipment fittings allow for fast color changes and application of very different fluid viscosities
HVLP systems, however, do have some disadvantages, including difficulty in obtaining higher fluid delivery rates with high viscosity materials, and a lack of sufficient atomization required for some fine finishes.
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Powder Coating
Powder constituents are very similar to wet paint with resins, pigments, and additives, but lack a solvent carrier. When powder coating, powder is supplied to the spray gun by the powder delivery system. This delivery system consists of a powder storage container, or feed hopper, and a pumping device that transports a stream of powder into hoses or feed tubes. Compressed air is often used as a pump because it aids in separating the powder into individual particles for easier transport. Powder spray guns impart an electrostatic charge to the powder being sprayed via a charging electrode located at the front of the spray gun. Managing the electrostatic field can direct the powders flow and control pattern size and shape, and powder density as it is released from the gun. All spray guns can be classified as either manual or automatic. Although basic operating principles of most guns are the same, an almost limitless variety in style, size, and shape of spray guns exists. The type of gun chosen for a given coating line can be matched to the performance characteristics needed for the products being coated. Powder coating became a major factor in the metal finishing industry when the electrostatic spray process (see next section) was introduced in the 1960s. Electrostatic spraying made it possible to apply thin layers of coating for higher quality decorative finishes, and allowed powders to be used on parts not suitable for dipping in a fluidized bed. As the powder coating technology continues to develop, advances have been made in powder formulations to offer a wider range of colors, glosses, and textures. The higher transfer efficiencies associated with powder coating are partially due to the recycling and reuse of powder overspray.
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Other Technologies
Rotary Atomizers
Paint is fed to the center of a spinning disk or bell, and use centrifugal force to break the paint into droplets. These devices use electrostatic charge to guide the paint to the part being coated. Electrostatic charging also plays a key role in atomizing the paint at low speeds. Rotary atomizers are well suited for covering large, broad surfaces; have high transfer efficiencies; and have high solid, waterborne versatility. Other advantages include the creation of a spray without use of thinner and higher transfer efficiencies. These systems do have some drawbacks, including increased equipment maintenance needs and safety hazards.
Dip Coating
Parts are coated by being dipped into vats of paint. Dip coating requires paint viscosity to remain constant to assure acceptable film quality and is not suitable for items with cavities. This process works well on parts that are always the same color and have minimum decorative finish requirements, such as agricultural equipment.
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Flow Coating
These systems use 10 to 80 separate streams of paint that coat all the parts surfaces. Like dip coating, this process is best suited for standardized color needs with low decorative finish requirements. Paint viscosity controls coating thickness, and an area must be provided for the part to hang while dripping excess paint.
Autodeposition
This process relies on a chemical reaction to deposit an organic coating onto iron, steel, zinc, and zincalloy plated materials. The part is immersed into a solution containing the coating compounds. When the part is submerged, the paint compound precipitates out of the solution and coats the part. The part is then removed from the tank, rinsed, and cured. This process does not use organic solvents, so no VOCs are emitted.
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Electrodeposition
This system, like the autodeposition system, requires the part to be immersed in a waterborne coating. The cosolvent is typically an organic solvent. The process is very much like electroplating in that the reaction is driven by electricity. Direct current is passed through the solution and causes a reaction with the paint resin, which deposits onto parts, creating a uniform coating. Although the coating contains some solvent, this process has low VOC emissions. Electrodeposition does have a high initial investment cost and intensive maintenance requirements. Separate tanks and rinse lines are needed for each color.
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A Comparison of Coatings
Traditionally, paint has been considered a liquid made up of several components that when applied and cured impart a thin plastic film. Paints have traditionally been organic solvent-based, with the solvents aiding in the application process. While being versatile, it has many environmental issues associated with its use, including air emissions and hazardous waste disposal. Highsolids paints have a higher percentage of paint solids and contain less solvent, and while air emissions may be less, they are still present. Waterbased paints, which utilize water as the solvent, also have reduced VOC emissions, as well as a reduced fire hazard. Solid paints, such as powder coatings and paints containing no solvents (and hence have reduced HAP and VOC emissions), are widely available. These materials have given rise to the term coatings instead of paints. With catalyzed or two-component coating systems, reactive resins and catalysts are mixed just before entering the application equipment. This type of coating system can also reduce solvent use. The following provides a comparison of four different coating technologies high-solids coatings (where the paint was modified to produce a coating with higher solids concentration and a lower VOC concentration), waterborne coatings (which mainly use water to disperse the paint resin, although some solvent is still present), powder coatings (which have become a viable alternative for decorative and functional coatings, although still predominately a metal-finishing process), and UV-cured coatings (coatings requiring UV radiation to initiate crosslinking of the resin).
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High-Solids Coatings
Pollution prevention benefits: s reduces solvent in coatings s less overspray compared to conventional coatings s higher transfer efficiencies Operational benefits: s can apply thick or thin coat s easy color blending or changing s compatible with conventional and electrostatic application equipment Energy savings: s reduced air flow in work spaces and curing ovens (low VOC) s reduced energy needed for heating makeup air Applications: s zinc-coated steel doors s miscellaneous metal parts s same as conventional coatings Limitations: s solvent use not completely eliminated s shorter pot life than conventional coatings
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Water-Based Coatings
Pollution prevention benefits: s eliminates or reduces solvent in coatings s reduced VOC emissions and fire hazards s reduced hazardous waste disposal s water used for cleanup Operational benefits: s can apply thick or thin coat s easy color blending or changing s compatible with conventional and electrostatic application equipment Energy savings: s reduced air flow in work spaces (little or no VOC) s reduced energy needed for heating makeup air Applications: s wide range s architectural trade finishers s wood furniture s damp concrete Limitations: s coating flow properties and drying rates can change with humidity, affecting coating application s sensitive to humidity, workplace humidity control required s may have poor flow characteristics due to high surface tension of water s special equipment needed for electrostatic application s water in paint can cause corrosion of storage tanks and transfer piping, and flash rusting of metal substrates
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Powder Coatings
Pollution prevention benefits: s eliminates solvent in coatings s little or no VOC emissions s easier to recycle and reuse overspray s reduces solvents for cleaning s reduces need for solid paint waste disposal Operational benefits: s can apply thick coat in one application s no mixing or stirring s efficient material use, possible to achieve nearly 100% transfer efficiency if a reclaim system is used Energy savings: s little air flow needed for worker protection (no VOC) s little energy needed for heating makeup air Applications: s steel s aluminum s zinc and brass castings Limitations: s requires handling of heated parts s part must be electrically conductive, complex shapes difficult to coat s difficult to apply thinner coatings s need special equipment or extra effort to make color changes s difficult to incorporate metal flake pigments
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Better operating practices, or good housekeeping applies to all waste streams and requires minimal capital investment, yet can be very effective in reducing the amount of wastes generated. Good housekeeping includes management initiatives to increase employee awareness of the need for and benefits of pollution prevention, and preventive maintenance to reduce the number of leaks and spills.
Waste assessments help identify the amounts and types of wastes generated at your facility. Knowing this makes it easier to know how waste can be reduced and where to concentrate your efforts. Any waste management program is an organized and continuous effort to systematically reduce waste generation, and should reflect the goals and policies of management. An effective program also includes the involvement and enthusiasm of employees, especially those who have an understanding of the processes being examined.
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Inventory control Better housekeeping practices Priority 1: Source Reduction Operator training High-transfer efficiency equipment Alternative coatings Better cleaning methods On-site solvent recycling Priority 2: Recycling & Reuse Off-site solvent recycling Waste exchanges Proper disposal
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Inventory Control
Inventory control is an effective and efficient way of reducing indiscriminate use of raw materials. By reducing the amount of paint that becomes unusable, you not only save costs associated with waste disposal, but you also save costs associated with initial product purchase. Mark receiving dates on your incoming paint products, and use a first in, first out procedure to use older paint materials first.
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If you have paint material that for one reason or another will not meet your clients specifications or expectations as a finished coat, use it as an undercoat or primer; or see if you can find a business that can use the paint and sell it, even at reduced cost. Monitor the amount of paint used by different workers to get the same jobs done. Shop owners may monitor employee operations and make verbal or written comments on product usage. Limit employee access to material storage areas, or develop some kind of accounting system to track material use.
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Keep paint and solvent containers tightly closed to reduce evaporation, emissions, and material dry-out. Reduce leaks and spills by placing drums at points of highest use. Use spigots or pumps when transferring materials from storage containers to smaller containers. Control evaporation by using tight-fitting lids and spigots. Use drip pans. Use secondary containment in bulk storage areas. Move drums carefully to prevent damage or punctures, which could lead to leaks or ruptures during future use.
Material Preparation
Look for ways to reduce the amount of solvent used in product pre-cleaning. Examine substituting chemical cleaning for physical or mechanical cleaning when preparing the product
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surface for painting application. Sand or particle blasting are some examples, although they have their own environmental issues. Plastic media has been substituted for sand in some blasting operations for both environmental and worker health issues. The plastic media can be reused once separated from the stripped-paint waste, reducing both purchasing and waste disposal costs. Dry ice is another alternative material for blasting processes. If solvent cleaning is used, reduce solvent loss due to evaporation by installing cleaning tank lids or increasing freeboard space in vapor degreasers.
Paint Mixing
For small jobs, the amount of paint prepared will often exceed the amount of paint actually applied. Track usage rates for different paint types. Have various sizes of paintmixing and sprayer cups available to limit over-mixing of paint for a specific project, and to reduce the amount of solvent needed for equipment cleanup.
Conversion Coatings
Avoid dirtying or soiling the substrate prior to the beginning of the cleaning process. Analyze water for hardness and dissolved solids. Use alkaline cleaners or phosphate compounds with hard water stabilizers where necessary. Use low-temperature, energy-conserving alkaline cleaners or phosphate compounds.
Do not arc the spray gun and blow paint into the air. Maintain a fixed distance from the painted surface while triggering the gun. Too much or too little overlap leads to wasted paint and heavy or lightly coated areas. A 50% overlap pattern is typically recommended.
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Air pressure should be kept lowthis can increase transfer efficiency from 30 to 60 percent. Keep the gun perpendicular to the surface being painted. Angling the gun leads to some of the spray being too far from your product surface and a decrease in transfer efficiency.
Ask your operators where they see improvements could be madeafter all they work with the equipment daily and may have suggestions not previously thought about. Provide incentives to increase employee participation in whatever waste reduction or recycling program you have. One business tracked the savings in material purchases and money made from recycling activities and put this into a general employee account to be used by the workers to improve their working stations and lunchroom.
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formance depends on the condition of their tools. Poorly maintained equipment may result in products that dont meet customer demand and can reduce the transfer efficiency of your operations.
Alternative Coatings
VOC emissions are related to the type of coating used and the number of coats necessary for a high quality finish. Acrylic lacquers are typically thinned with solvent by 125 to 150 percent. With synthetic enamels, solvent thinning amounts to 15 to 33 percent. Minimize or eliminate VOC emissions by substituting solventbased paint with waterborne paint, high-solids paint, or with mediumor low-solvent paint. Consider, however, the desired final product specifications and the type of product being coated when choosing substitute materials.
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Filters
Suppliers or recyclers of thinners may replace and dispose of dirty spray booth filters for a generator. It is the responsibility of the generator, however, to determine if these filters are hazardous. Filters may be characteristic hazardous waste (toxicity) if they contain enough metals or volatiles. The volatiles could come from the paint thinners used or from the paint itself. The metals typically are found in paint pigments. When cleaning paint equipment (including gun tips and hoses), solvent and/or thinners should not be sprayed on filters (or into the air in the paint
booth), as this could cause the filters to become a listed waste (and this act is considered illegal disposal). Because the filters are in a solid state rather than a liquid, they are not considered a hazardous waste in Kansas due to ignitability (D001). It is important to remember, however, that paint filters have been known to cause trash fires and that some local trash haulers and transfer stations will not allow them to be disposed in the regular trash. In this case, the filters should be segregated from the regular trash and disposed under a Special Waste Disposal Authorization from KDHE.
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Since the flow of coating from the gun is consistent, the speed of the gun as it is moved across the part should be consistent as well. Steady gun speed will help obtain a uniform thickness of coating. A gun speed higher than manufacturer specifications can distort the spray pattern and not permit the maximum amount of material to reach the surface. The distance of the gun from the part must be consistent, since, again, the flow of material from the gun is consistent. Generally, this will be six to eight inches for non-electrostatic systems. Spray losses increase with the distance, as does solvent loss. This solvent loss is often corrected by the addition of more solvent. This does not correct the spray loss, and overspray still ends up in the spray booth.
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proper overlap of the spray pattern proper gun speed proper distance of the gun from the part holding the gun perpendicular to the surface of the part triggering the gun at the beginning and end of each stroke
Proper overlap of spray patterns will be determined by the coating. Proper overlap may range from 50 percent to 80 percent. Greater overlap may result in wasted strokes, and less overlap may result in streaks.
Ohio Environmental Protection Agency, Office of Pollution Prevention, September 1994, Pollution Prevention in Painting and Coating Operations
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Except for special conditions, the gun should be held perpendicular to the surface of the part. Arcing the gun for hard-to-reach areas wastes material by applying an uneven coat. This also may result in streaks. These areas should be compensated for by changing the positioning of the gun or operator. If the trigger of the gun is not released at the end of a stroke, the material continues to flow and when the gun changes direction, momentary stopping of the gun results in an accumulation of coating material. To avoid this piling, the operator may spray past the edge of the surface, spraying material into the spray booth and wasting coating.
All manufacturer specifications should be checked to ensure that operators are using the proper technique for their equipment. Operator training and experience will provide operators with knowledge of various painting techniques needed to paint parts of different configurations. Different techniques are helpful when painting inside corners, outside corners, slender parts, round parts, flat parts, large parts, or small parts. Standard operating techniques will not be fully successful if other problems exist, such as room temperature changing throughout the day (which changes the viscosity of the paint) or if equipment needs repair. Operators cannot be expected to compensate for broken gauges, worn fluid tips, or other equipment problems.
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Regulatory Issues
Pollution generated from industrial coating applications can come from a variety of sources, including spent paint, paint sludge, and paint filters. Dirty thinner from the cleaning of spray guns and paint cups, rags contaminated with cleaning or paint materials, and unused coating products are other wastes. Inefficient coating transfer operations and equipment cleaning are major sources of waste generation, and loss of hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) during the application and drying processes may even cause small businesses to be classified as major sources of air pollution. The potentially significant amount of pollution generated from these and other painting processes causes industrial coaters to fall under four major categories of environmental regulations affecting their operations: hazardous waste, air, water, and right-to-know reporting. Workplace safety must always be considered as well. This section contains brief summaries of these regulations. A list of who to contact for more information can be found at the end of this publication.
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Ignitable:
The substance has a flashpoint less than 140F.
Reactive:
The material vigorously reacts with air or water, has a tendency to explode, or produces toxic gases.
Toxic:
It is deemed toxic according to approved toxicity tests.
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Paint and related solvent wastes often display ignitable or toxic characteristics. While oil- or solventbased paint wastes are usually ignitable, some water-based paints can also be ignitable because of the drying agents they contain.3 These wastes may also contain a regulated metal pigment such as chromium or lead. Waste material can also be considered hazardous if it is on EPAs list of hazardous wastes (F-list, K-list, Plist, and U-list), found on pages 24 through 45 of the Hazardous Waste Generator Handbook. Check your material safety data sheets to see if your paints, paint thinners, or cleaners contain any of these wastes. Common solvents in painting operations are classified as hazardous and are found in the F001 to F005 waste number categories (page 24). Examples of such solvents include xylene, acetone, methanol, methyl isobutyl ketone, toluene, methyl ethyl ketone, and benzene, among others.
Minnesota Pollution Control Agency, September 1997, Evaluating Paint and Ink Wastes
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are specifically exempt (page 3 of the Hazardous Waste Generator Handbook) may be left in the bottom of containers that have been completely emptied by conventional means such as pouring and pumping. Containers are considered empty if no more than one inch of residue remains on the bottom, or no more than three percent by weight of the contents remain inside a container that is 110 gallons or less, or no more than 0.3 percent by weight of the contents remains inside a container than is larger than 110 gallons. If the container contained a P-listed waste, it must be triple-rinsed before being considered empty.
are managed in an elementary neutralizing unit, a totally enclosed treatment unit, or a permitted wastewater treatment unit are legally allowed to be discharged directly to a publicly owned treatment works (POTW)
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The facility generates no more than 55 lbs of hazardous waste, or no more than 2.2 lbs of acutely hazardous (P-listed) waste in a calendar month. The facility accumulates no more than 2,200 lbs of hazardous waste or no more than 2.2 lbs of acutely hazardous waste, or no more than 55 lbs of debris and contaminated materials from the cleanup of spillage of acutely hazardous waste.
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However, when, as a small quantity generator, you accumulate more than 55 pounds, you must do the following:
Package, label, mark, and placard all shipments of hazardous waste. All containers of hazardous waste must be marked with the words Hazardous Waste. Follow the dating and marking requirements for containers and tanks. Document weekly inspections of hazardous waste storage sites.
Small quantities of hazardous waste may NOT be disposed of by dumping on the surface of the ground or into surface waters, burying in the ground at an unpermitted site, or by using wastes such as solvents for killing weeds.
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Kansas Generator
Each of the following criteria must be met to be considered a Kansas generator: Kansas generators must comply with the following regulatory requirements: a) Determine which wastes generated by the facility are hazardous b) Obtain an EPA identification number by submitting a hazardous waste notification form to the Kansas Department of Health and Environment. (This form is available in Appendix B of the Hazardous Waste Generator Handbook.) c) Prepare a manifest for all shipments of hazardous waste. Package, label, mark, and placard all shipments of hazardous waste in accordance with pretransportation requirements. (This form is can be found in Appendix C of the Hazardous Waste Generator Handbook.)
The facility generates 55 lbs or more of hazardous waste but less than 2,200 lbs in a calendar month, and the facility does not generate 2.2 lbs or more of acutely hazardous waste or 55 lbs or more of debris and contaminated materials from the cleanup of spillage of acutely hazardous waste. The facility accumulates no more than 2,200 lbs of hazardous waste or 2.2 lbs of acutely hazardous waste, and no more than 55 lbs of debris and contaminated materials from the cleanup of spillage of acutely hazardous waste.
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d) Prepare and maintain the following records for three years: 1) a signed copy of all manifests initiated 2) manifest exception report(s) 3) hazardous waste analyses 4) weekly inspection reports e) Meet all storage requirements for containers and/or tanks. f) Meet emergency preparedness requirements. g) Report all international shipments of hazardous waste to the Kansas Department of Health and Environment and the Environmental Protection Agency.
The above list is an abbreviated version of compliance requirements. For a complete listing of requirements associated with hazardous waste, please consult the Hazardous Waste Generator Handbook, the Kansas Statutes Annotated, Chapter 65Article 34, and the Administrative Regulations, Article 31.
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EPA Generator
An EPA generator is one who fulfills any one of the following: EPA generators are subject to all regulations for Kansas generators, except for the emergency preparedness requirements, as well as the following additional requirements: a) Provide a personnel training program to ensure that facility personnel are able to respond effectively to a hazardous waste emergency. The program must include the following: 1) a director trained in hazardous waste procedures 2) instruction which teaches facility personnel about the location of emergency response and monitoring equipment; maintenance and operation of such equipment; communications procedures and response procedures for fires, explosions, and contamination incidents (training must be completed within six months after the date an employee enters a position) 3) an annual review of the initial training
The facility generates in any single month or accumulates at any time 2,200 lbs or more of hazardous waste, or generates in any single month or accumulates at any time 2.2 lbs of acutely hazardous waste. The facility generates or accumulates at any time more than 55 lbs of debris and contaminated materials from the cleanup of spillage of acutely hazardous waste.
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4) development of job titles and descriptions, a description of training to be given each job title, and a record of all training which occurs b) Adequately provide for preparedness and prevention with the following precautions: 1) proper maintenance of facilities to minimize releases of hazardous waste 2) where appropriate for the type of waste generated, provide an internal communications or alarm system, a telephone or two-way radio, and fire extinguishing and control equipment (all required equipment must be tested and maintained to ensure proper operation) 3) provide personnel working directly with hazardous waste with immediate access to communications and alarm equipment 4) maintain aisle space sufficient to allow passage of personnel and fire, spill control, and decontamination equipment
5) make arrangements with the local hospital, police department, fire department, and emergency response team to familiarize them with the plant layout and hazards involved with the wastes generated (such arrangements should be documented) c) Prepare a contingency plan and implement emergency procedures to ensure that releases of hazardous waste are properly handled. The contingency plan must provide for: 1) a description of actions facility personnel must take to respond to a release 2) a description of arrangements made with local authorities for emergency services 3) designation of primary and secondary emergency coordinators and listing of their addresses and phone numbers 4) a list of all emergency equipment on site, including capabilities and locations
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5) an evacuation plan where potential need for evacuation exists 6) copies of the contingency plan to be maintained at the facility and submitted to the local police department, fire department, hospital, and emergency response team 7) a contingency plan that is to be periodically reviewed and current
The above list is an abbreviated version of compliance requirements. For a complete listing of requirements associated with hazardous waste, please consult the Hazardous Waste Generator Handbook, the Kansas Statutes Annotated, Chapter 65 Article 34, and the Administrative Regulations, Article 31.
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Choosing a reputable hauler and facility with EPA ID numbers. If you have questions about who to call to determine if they are reputable, contact SBEAP at 800-5788898. Packaging and labeling all wastes appropriately. Preparing hazardous waste manifest.
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Air Regulations
With the enactment of the Clean Air Act Amendments (CAAA) in 1990, the way air emissions are regulated was reorganized. One change was regulated hazardous air pollutants (HAPs). The current list of HAPs contains 187 chemicals and can be found on the internet at www.epa.gov/ttn/atw/orig189.html. Many paints contain significant quantities of HAPs such as toluene, xylene, methyl ethyl ketone (MEK), or methyl isobutyl ketone (MIBK). The amount of HAPs or volatile organic compounds (VOCs) your facility has the potential to release or emit will determine if your business is required to obtain an operating permit and/or comply with other regulatory requirements. facility has the potential to emit more than the above stated amount of HAPs or VOCs, or if it falls under specific air regulations or national emission standards for hazardous air pollutants (NESHAPs).
Major Sources
Painters and coaters are subject to limits on their VOC and HAP emissions from solvents used in paints, paint stripping, or cleaning. Your facility is defined as a major source of air pollution if it has the potential to emit:
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10 tons of any single HAP 25 tons of any combination of HAPs 100 tons or more of any other regulated air pollutant in a single year. Such pollutants include nitrous oxides, sulfur oxides, particulate matter less than 10 microns, or VOCs.
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There are other regulated pollutants that typically dont apply to coating processes but may affect your facility if painting is only one part of your total operation.
Your potential to emit, or PTE, is based on the maximum amount of air pollution your facility would emit if
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Class I Permits
The Class I operating permit is a single document that contains all air quality requirements your facility has to meet. If your facility is defined as a major source, then it will need a Class I permit. As stated above, Class I status is based on your business potential to emit various air pollutants.
each process unit is operated at 100 percent of its physical and operational design capacity materials that emit the most air pollutants are used 100 percent of the time all of the equipment is operating 24 hours per day, 365 days per year no pollution control equipment is used
The Class I permit application process can be very involved, time consuming, and expensive. Once KDHE receives your application, it has 60 days to determine whether it is complete. Both the public and the U.S. Environmental Protection Agency can participate in the application review process. Once issued, your permit is good for five years, and you will need to submit a renewal application at least six months before it expires.
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Class II Permits
If your facilitys actual emissions are less than the major source thresholds, but the potential emissions still exceed them, then your facility may qualify for a Class II permit, which is less expensive and time consuming to complete than the Class I permit. The Class II permit allows you to specify how you will limit your potential emissions to below the major source threshold and thus avoid the need for a Class I permit. The Class II permit application asks for information KDHE needs to determine your facilitys potential-to-emit, such as material safety data sheets and chemical usage rates, and how you will limit your potential to emit. Both the public and EPA can review the permits, in addition to KDHE. Once issued, the permit remains valid with no required renewal unless it is revoked or you are unable to limit your potential emissions to below the major source thresholds. Air emission limits and material tracking requirements may be part of a Class II permit. By June 1 of each year, you will need to submit operating information, such as material usage rates and MSDSs for the previous year, so KDHE can recalculate your air emissions.
Other Restrictions
Certain counties have additional restrictions. In Kansas, facilities in Johnson and Wyandotte counties are restricted to using coatings with low VOC content. Current regulations mainly affect surface coating of miscellaneous metal parts and products and metal furniture, at facilities with have potential VOC emissions greater than three tons per year. For example, regulations limit the VOC content to 3.5 pounds per gallon for coatings.
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cations at existing facilities can meet applicable Kansas and federal air quality requirements. You need a construction permit if your potential to emit, or your increase in potential to emit, exceeds the levels shown below, or if the construction activity includes an incinerator.
Pollutant
Lead PM10 PM SOx VOC NOx CO HAPs (individual) HAPs (any combination)
If you are not required to obtain a construction permit, you may need a construction approval if you will be a new or modified source and
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you are subject to a New Source Performance Standard (NSPS) your facility is subject to a maximum achievable control technol-
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Pollutant
Lead or lead compounds SO2 or SO3 PM10 PM NOx CO
(Areas Except for Wyandotte and Johnson counties) VOCs 50 pounds per 24 hours
The primary difference between a construction permit and a construction approval is that the permit requires an application fee while the approval does not. The fee is equivalent to 0.05% of the capital cost of the proposed activity.
If you need to obtain an operating permit or construction permit/approval form, visit the KDHE Bureau of Air and Radiations Web site at www.kdhe.state.ks.us/bar/index.html, or call SBEAP at 800-578-8898.
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Often times, the weight percent of HAPs or VOCs are also given on the MSDS. If your MSDS happens to give you volume percents rather than weight percents, you will have to do a quick calculation to get the weight percent of the particular pollutant. HAP wt% = (HAP density) x (product volume) x (HAP volume%) 100
Acetone is an example of a VOC which is exempt. Now that you have all your information, you can calculate your actual and potential emissions for your pollutants of concern.
Actual emissions = (product volume used annually) x (product density) x (wt% of pollutant) Potential emissions = (actual emissions) x (8760 hours) (actual operating hours) The Kansas Small Business Environmental Assistance Program, SBEAP, has several publications to help you understand the air regulations and can assist you in determining your potential air emissions. SBEAPs toll free number is 800-5788898, and you can visit our Web site at www.sbeap.org.
Determining your VOC weight percent is a little different, because VOCs are contributed to by many chemicals in your product. The easiest way to calculate your VOC weight percent is by the following: Wt% VOC = 100 (wt% of solids) (wt% of water) (wt% of any exempt VOCs)
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Wastewater Regulations
The primary objective of the Clean Water Act (CWA) is to restore and maintain the chemical, physical and biological integrity of the nations surface waters. Pollutants regulated under the CWA are classified as priority pollutants. These include various toxic pollutants; conventional pollutants, such as biochemical oxygen demand (BOD), total suspended solids (TSS), fecal chloroform, oil and grease, and pH; and non-conventional pollutants, including any pollutant not identified as either conventional or priority. Under the Clean Water Act, point sources of wastewater (discharge pipes or sewers) discharging to waterways require a National Pollutant Discharge Elimination System (NPDES) permit. Permits, issued by the Kansas Department of Health and EnvironmentBureau of Water, specify levels of toxicity and other characteristics that must be achieved prior to discharge. Some businesses discharge wastewaters from phosphating processes or waterfall paint booth units via their NPDES permit. Treatment of the wastewater is generally necessary. Wastewater generated from coating applications might be regulated because of the presence of organic solvents or heavy metals. Use of wastewater treatment systems which do not discharge or direct waste to a POTW are also regulated by KDHE. Wastewater ponds which do not discharge are not regulated under the NPDES program but will still require a Kansas water pollution control permit. Wastewater ponds which receive industrial waste have special requirements regarding their construction and permitting. KDHE should be consulted.
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Another type of discharge regulated by the Clean Water Act is one that goes to a publicly owned treatment works (POTW). The national pretreatment program controls the indirect discharge of pollutants to POTWs by industrial users. Facilities regulated under this program must meet certain pretreatment standards. Recent rules require facilities that utilize the phosphating process and discharge to a POTW be permitted due specifically to this type of discharge. If discharging to a POTW, contact KDHE to determine the applicability of pretreatment requirements and permitting requirements. The goal of the pretreatment program is
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Reduced water use is the primary waste reduction option for phosphatizing. Water needed to maintain the bath solution can be reduced by monitoring temperature, chemical concentration, and the pH level. Reuse solution or rinse water from one bath to others when possible. What is your source of water? Is it deionized or tap water? City water can bring in considerable amounts of dissolved solids, and these contaminants can vary seasonally. Properly matching the phosphating chemicals with the metal substrate is another key issue in minimizing waste from phosphating operations. This can significantly minimize sludge generation.4
to protect municipal wastewater treatment plants from damage that can occur when hazardous, toxic, or other wastes are discharged into a sewer system to protect the quality of sludge generated by these plants
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Directing industrial waste to a septic tank is prohibited. Contact KDHE or SBEAP if you have questions.
N.C. Division of Pollution Prevention and Environmental Assistance. Pollution Prevention in Metal Painting and Coating OperationsA Manual for Pollution Prevention Technical Assistance Providers. April 1998
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Water Regulations
If the facility is served by a municipal or rural water discrict line, there are no public water supply program issues to address. If the facility utilizes its own source of water or potable consumption, and serves 25 people more than 60 days per year, the facility is considered a public water supply and needs to be permitted by KDHE.
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Reporting Spills
Spills of hazardous substances must be reported to the appropriate authority if reportable quantities are spilled. These quantities range from 1 to 5,000 pounds of substances spilled within a 24-hour period. Reportable quantities are often found on the MSDS provided with the material. In many cases, local authorities require facilities to report smaller spills. The number for the U.S. EPA National Response Center is 800-424-8802. The 24hour spill response number for the Kansas Department of Health and Environment (KDHE) is 785-2960614.
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Kansas Tier II
Section 312 of EPCRA requires facilities to submit an inventory of the hazardous chemicals stored on site, if threshold quantities are met. Facilities required to submit MSDSs under Section 311 are required to comply with this section for the chemicals they report under 311. The inventory must be submitted on Tier II reporting forms. The Kansas Department of Health and Environment (KDHE) has the form on its Web site at www.kdhe.state.ks.us. This information is to be submitted to KDHE, your local emergency response committee, and your local fire department. These forms contain more detailed information on the chemicals stored onsite and the locations of those chemicals at the facility. The Tier II form is an annual form due March 1.
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You must file a Kansas Tier II form if you have at your facility more than 10,000 lbs of any chemical OSHA requires you to have a MSDS for; or you have either 500 lbs or the threshold quantity, whichever is smaller, of an extremely hazardous substance (EHS). Some common EHS include nitric acid, sulfuric acid, and ammonia. A complete EHS list can be obtained by calling SBEAP at 800-578-8898.
Form R
The aspect of EPCRA that has gotten the most publicity is the requirement under Section 313 whereby facilities that routinely and/or accidentally release a defined set of chemicals must report annually on those releases. Compilation of this information is called the toxics release inventory, or TRI. Reports are due to the EPA, with copies sent to KDHE, by July 1 of each year. Facilities required to report have the following characteristics:
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use any of the designated chemicals at a rate of 10,000 lbs or more a year; or
manufacture and process any of the designated chemicals at a rate of 25,000 lbs or more a year.
be classified in SIC codes 10 (except 1011, 1081, 1094), 12 (except 1241), 20-39, 4911, 4931, 4939, 4953, 5169, 5171, or 7389;
Because the list of chemicals to which the TRI requirements apply is revised periodically, it is important to get an approved list from KDHE or by calling SBEAP at 800-578-8898.
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If you are located in Kansas, an excellent resource for businesses with OSHA-related questions is the Kansas Department of Human ResourcesIndustrial Safety Division. They will conduct free, voluntary OSHA audits if requested by the facility owner. Businesses participating in this program are required to correct any serious violations found. They can be reached at 785-296-4386. The regional office for OSHA (for Kansas, Nebraska, Missouri, and Iowa) can be reached at 816426-5861. In Kansas, the Wichita OSHA office can be reached at 316269-6644.
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General Information
SBEAP (Small Business Environmental Assistance Program): KDHE: Public advocate 800-578-8898 785-296-1500 800-357-6087
Air
Air Permits and Emission Calculations KDHE: Technical Assistance with Air Emissions SBEAP: 785-296-1593 800-578-8898
Waste
Waste Management Requirements KDHE: 785-296-1600
Wastewater
Wastewater Requirements KDHE: For cities: KDHE: For industry: KDHE: Pretreatment requirements: KDHE: Industrial waste to septic tanks: 785-296-5525 785-296-5547 785-296-5551 785-296-5560
Water
Water Requirements KDHE: Public water supply: 785-296-5503
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Storage Tanks
KDHE: Fire Marshal: 785-296-1660 785-296-3401
Right-to-Know
KDHE: 785-296-1689
Pollution Prevention
Technical AssistanceFree and Non-regulatory SBEAP: 800-578-8898
OSHA-Related Questions
OSHA regional office Wichita OSHA office Kansas Department of Human Resources 816-426-5861 316-269-6644 785-296-4386
This publication was created by Kansas State Universitys Pollution Prevention Institute through the Small Business Environmental Assistance Program (SBEAP). SBEAPs mission is to help Kansas small businesses comply with environmental regulations and identify pollution prevention opportunities. SBEAP is funded through a contract with the Kansas Department of Health and Environment. SBEAP services are free and confidential. For more information, call 800-578-8898, send an email to SBEAP@ksu.edu, or visit our web site at http://www.sbeap.org. Kansas State University is an EEO/AA provider. 6/0225
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